Getting a client to sign a promissory note for legal fees owed has a substantial benefit – it can cut off a dispute over the reasonableness of the legal fees in a subsequent collection action.

Appellants cite Hall v. Fowler, 389 S.W.2d 730, 732 (Tex. App.–Dallas 1965, no writ), in support of their argument that when a client has given a promissory note in lieu of payment for legal services already rendered, the client is estopped from later claiming that the charges for such services were not reasonable. In Fowler, a client executed a promissory note to her attorney for legal fees rendered pursuant to the client's divorce. 389 S.W.2d at 731. After the client defaulted, the attorney sued and moved for summary judgment, which was granted and affirmed on appeal, even though the former client claimed inadequate consideration for the note. Id. at 732. In affirming the summary judgment in favor of the attorney, the Fowler court stated:

One cannot receive and accept the personal services of another, and thereafter execute a promissory note for the amount of the fee demanded by the one performing the services, and then defeat liability on that note by contending that the services were not worth the amount of the note. If there was a question as to the value of services already rendered, that question must be considered as resolved by the execution of the note.

Id. We agree with the Fowler court's reasoning.

Tummel & Casso v. Snyder, No. 13-04-223-CV, 2007 Tex. App. Lexis 1208 (Tex. App.–Corpus Christi 2007).